Laboratory for Freshwater, Marine Research  

Underwater Cleaning for Professional Shipping [more]

>> to archive


Archive: Status of the implementation of the EU-Biocide Directive regarding PT21 and PT11

The EU-Biocide-Directive was adopted in 1998 and has been implemented since 01.09.2013 as the EU-Biocide-Regulation and transferred into national law. Regarding fouling protection of the hull of ships and seawater intakes approved biocides and products will be regulated in the product types 11 and 21. The two product types are defined as follows:

PT 11 Preservatives for liquid-cooling and processing systems
Used for the preservation of water or other liquids used in cooling and processing systems by the control of harmful organisms such as microbes, algae and mussels.
Products used for the disinfection of drinking water or of water for swimming pools are not included in this product-type. According to this definition product type 11 refers to seawater cooling intakes and fire fighting systems of ships and offshore installations.

PT 21 Antifouling products
Used to control the growth and settlement of fouling organisms (microbes and higher forms of plant or animal species) on vessels, aquaculture equipment or other structures used in water. According to this definition product type 21 refers to antifouling systems applied to ship or boat hulls as well as for the fouling prevention of aquaculture installations.

In the process of the implementation of the EU-Biocide Regulation the following provisions and schedules are relevant for PT 21:

  • Notified biocides for which a dossier has been submitted can be used until final decision.

  • Notified biocides for which no dossiers habe been submitted are banned since 2008 (e.g. Diuron and Chlorthalonil).

  • Until the end of 2015 all biocides in PT 21 applied for approval must had been finished and the dossiers had to be presented to ECHA.

  • At the end of 2016 all biocides decisions have to be adjudicated on the EU level.

  • 2019 at the latest, for all products an authorization has to be applied to get them marketable.

  • Likely in 2020/2021 exclusively authorized antifouling products are placed on the EU market.

  • National exemptions in the authorization of biocides and products can be expected due to environmental and human health aspects (art. 37). Some products may not be authorized for end users but authorized for professional application and use (art. 19).

Current status of implementation: 
Since 31st of January 2014 the following active agents have been approved: 

  • zineb

  • isothiazolinone (DCOIT)

  • tolylfluanid (not allowed in fresh water!)

  • copper-pyrithione (not allowed for do-it-yourself application!)

  • dicopper oxide

  • copper thiocyanate

  • copper flakes (coated with a film of aliphatic acid)

  • tralopyril

  • medetomidine

Irgarol (cybutryne) has been rejected and must not be used from February 2017.

Dichlofluanid and zinc-pyrithione have to be authorized or refused. Further restrictions of use may occur.

Efficacy tests
For PT21 Technical Notes of Guidance (TNsG) have been adopted prescribing efficacy tests as simulated field tests including fail/pass criteria for fouling prevention property. Efficacy testing shall be performed according to standard tests (CEPE or ASTM standards) during the fouling season in representative fresh- or saltwater locations. In addition, efficacy data may be submitted from world-wide exposure facilities and field tests on ships.

Non-biocidal systems
For non-biocidal systems like foul-release systems no efficacy tests are prescribed. Nevertheless, proven efficacy is of crucial importance for shipping companies and boat owners. It is highly recommended for companies bringing non-biocidal solutions to the market to present efficacy data comparable to those for biocidal products. An economic incentive may be an application for respective eco labels. In Germany and Europe a few suitable eco labels are in force:

  • IN EN ISO 14024 Biocide-free Antifouling Products

  • RAL UZ 110 Environment-Conscious Ship Operation

  • RAL UZ 141 Eco-Friendly Ship Design

The first label has been outlined for non-biocidal fouling prevention systems, for the others environmental friendly fouling prevention systems constitute one criterion among several others.




© LimnoMar, Dr. Watermann